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An Introduction to Partners Policies on An Introduction to Partners Policies on

An Introduction to Partners Policies on - PowerPoint Presentation

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An Introduction to Partners Policies on - PPT Presentation

Interactions with Industry Office for Interactions with Industry Partners HealthCare Updated October 31 2014 Click PLAY or FORWARD to move through the slides What do I need to know about interactions with industry ID: 361022

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Slide1

An Introduction to Partners Policies on

Interactions with Industry

Office for Interactions with IndustryPartners HealthCareUpdated October 31, 2014

Click

PLAY

or FORWARD to move through the slides. Slide2

What do I need to know about interactions with industry?Slide3

Decisions and judgments relating to our charitable activities should be based on the best interests of our patient care, research and educational missions.

External

financial interests create the concern that our decisions may be biased, or be perceived as being biased, by those financial interestsClinical Care – are patients’ interests foremost?Research – is the design, conduct, and reporting of research objective?

Education – is

the audience receiving unbiased information

?Bias can be real, but even the perception of biased decision-making can damage the individual’s and institution’s reputation, erode public trust and undermine Partners hospitals’ charitable activities – and create legal exposures.

Why is COI a concern?Slide4

What do I need to know?

The remainder of this tutorial will tell you about Partners rules and help you to manage your relationships with industry in a positive way. Topics include:

Outside Activities, including giving talks

Gifts

Industry Support of Educational Activities

Research and Personal Financial InterestsThe Office for Interactions with Industry (OII) and your Compliance Officer are here to help you to navigate the relevant Partners policies and procedures

!

Understanding Partners PoliciesSlide5

What is an Outside Activity?

Two Separate Paths can lead to an Outside Activity

Engagement in an activity beyond the scope of what you do at Partners

Activity that requires the expertise you use in your Partners position

Activity that involves a company that does or could do business with Partners, even a non-medical one

OR

OUTSIDEACTIVITY

OUTSIDE

ACTIVITYSlide6

What is an Outside Activity?

If

you have any questions about existing or new Outside Activities, please contact OII

!

Consulting, scientific advisory boards or Board of Director positions for:

Pharmaceutical companies

Medical device companiesFinancial services companies

Any other vendor or likely vendor of

Partners

Giving talks or a training presentation paid for by a commercial company

Online medical evaluations for non-Partners organizations

Expert

witness work

Examples of Outside ActivitiesSlide7

Serving in an executive position of a for-profit company engaged in commercial or research activities of a biomedical nature (for full-time HMS faculty and Institutional Officials only)

Certain types of company-paid speaking engagements (more on this later)

Ghostwriting

Prohibited Activities

What requirements are there around Outside Activities?

Partners

encourages and

supports engaging in outside activities. Most are allowable.

Only

a few are prohibited.Slide8

Compensation

– Payment should not exceed fair market value for time spent

Time – Medical staff who are full-time HMS faculty may spend up to 20% of working time on Outside Activities, not to exceed one day a week, unless limited by your supervisor. Non full-time HMS faculty must check with your supervisor about time permitted on Outside Activities.

Institutional resources

– For your Outside Activities, you

cannot make substantial use of institutional resources (space, materials, staff).Use of name/ Intellectual Property – Company may not use Partners & Partners hospitals’ names or claim Partners IP.General – The activity must be conducted so that the time and creative energy does not, in the supervisor’s judgment, compromise or interfere with individual’s responsibilities at Partners

Outside Activities have limits regarding

Written agreements are required when the outside activity is with an outside entity that is a pharmaceutical, medical device or biotechnology company or a vendor or potential vendor of Partners.

Most agreements require review by OII.,

to ensure compliance with institutional policies

Many arrangements also need supervisor approval

Consult OII’s Consulting & Outside Activities web page for details about when agreements require review and whether supervisor approval is required.

http://pulse.partners.org/OII/ConsultingHome.html

Partners policies require a written agreement for most Outside Activities

What requirements are there around Outside Activities?Slide9

What do I need to know about giving talks?

If talk is part of CME event hosted by ACCME accredited provider (or equivalent)

If presentation is hosted by, and pay is from, a professional society or academic institution

If presentation is hosted or directly paid for by a company, provided that the speaker has

FULL

control of content and the talk is not otherwise prohibited

OK

If talk is hosted or directly paid for by a company, it is not OK if

It is called a “Speakers Bureau”

The company has control over content

The speaker has agreed to be on a company-held list of available speakers

The speaker is engaged in promotional activity for the company

(See g

uidelines for determining whether an activity is promotional on OII’s web site.)

Not OK

Not sure?

Call OII

More than 6 talks or presentations/year/company

is

not allowed without

approval from the Committee on Outside Activities

(

formerly called the Committee on Conflicts of Interest)

.Slide10

What kind of gifts are acceptable?

No gifts may be accepted from vendors or potential vendors. Includes all vendors, not just drug & device companies.

*Are there times when a meal is not a gift? See FAQs, scenarios on OII’s web

page.

Entertainment: tickets, rounds of golf

Trinkets: pens

, mugs, tote bags Conference giveaways

Food/Meals *

NO GiftsSlide11

What do I need to know about Purchasing?Slide12

What do I need to know about Industry Support of Partners Educational Activities?

All

industry support of Partners educational activities must be processed through OII

!

Funding for a specific program must come from more than one company

Conferences must meet the standards of the ACCME or comparable standards, even if not for CME credit

Training programs, including residency and

clinical fellowship programs Educational events, such as Grand Rounds, lectures and conferences Newsletters and websites designed to deliver educational content

Program Requirements

Examples of Partners Educational ActivitiesSlide13

What do I need to know about Research?

Special concerns about conflicts of interest in research

Objectivity of data, conclusions impacted

Misuse of human subjects or patients; injury or worse

Misuse/ exploitation of students, trainees, junior faculty who are involved in research enterprise of conflicted supervising researcherSlide14

What do I need to know about Research?

Many research collaborations with industry are allowed and encouraged.

However, just a few arrangements are

not

okay:

Doing clinical research (regardless of funding source)

on the technology

of a company in which you/your family has financial interests (includes stock, other forms of equity, cash income), except if the only financial interest is cash income that does not exceed $10k/year.

Receiving research support either from a publicly traded company in which you/your family owns equity (stock, stock options, other ownership interests) with value greater than $30,000 or any equity in a privately held company.

Receiving research support from a company, or doing research on a technology of a company for which you serve on the

Board of DirectorsSlide15

The Partners Commission for Interactions with

Industry recommended implementing a policy and process for managing conflicts in clinical care.

In 2013, the Partners Committee on Outside Activities (formerly called the Committee on Conflicts of Interest) established a physician task force to study the issue in-depth. Recommendations from the Task Force are under consideration by Partners Leadership. Stay tuned!

What’s Ahead: Conflicts in Clinical CareSlide16

Where can I learn more?

The Partners Policy for Interactions with Industry is posted at :

http://www.partners.org/About/Ethics/Interactions-With-Industry/Policy.aspx

The key sections of the Policy are:

Section 1: Researchers’ Financial Interests and Outside Activities Related to Research and Financial Conflicts of Interest

Section 2:  Clinical Care and Interactions with IndustrySection 3:  Industry Support Related to EducationSection 4:  Consulting and Other Outside ActivitiesSection 5:  Institutional Conflicts of Interest

Partners Policy

Guidelines, FAQs, Resources and Forms related to Consulting Agreements, Industry Support for Educational Activities, Partners Disclosure Forms, Speaking Engagements, NIH Regulations affecting Sponsored Research

OII web siteSlide17

If you have questions, your Compliance Officer is knowledgeable about these issues and can help you work through them.

If you are entering into a new consulting or other outside activity, contact OII or visit OII’s web page.

Where can I get more help?Office for Interactions with Industry

Partners HealthCare

617-643-7752

PHSOII@partners.orgYour Compliance Officer and OII

are here to help!Slide18

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